https://www.taxtmi.com/caselaws?id=205180 The tribunal determined that the Comparable Uncontrolled Price (CUP) method was the appropriate approach for calculating the arm's length price of international transactions. It found that the Transfer Pricing Officer's rejection of the CUP method was unfounded, as market conditions were similar for the assessee and Chinese manufacturers. The tribunal emphasized the importance of contemporaneous documentation and directed the assessee to provide necessary data for reassessment using the CUP method. The appeal was partly allowed for statistical purposes. en-us Fri, 11 Feb 2011 00:00:00 +0530 Tue, 14 Jun 2011 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205180 The tribunal determined that the Comparable Uncontrolled Price (CUP) method was the appropriate approach for calculating the arm's length price of international transactions. It found that the Transfer Pricing Officer's rejection of the CUP method was unfounded, as market conditions were similar for the assessee and Chinese manufacturers. The tribunal emphasized the importance of contemporaneous documentation and directed the assessee to provide necessary data for reassessment using the CUP method. The appeal was partly allowed for statistical purposes. Case-Laws Income Tax Fri, 11 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205180